Transport Driver ADR Documentation

Driver ADR Written Instructions 

Drivers are required to carry 'Instructions in Writing' which is a 4-page document that sets out emergency information and emergency equipment. These replace Tremcards but, whereas Tremcards are issued by the sender of the goods, Instructions in Writing must be issued to drivers by their employers, the ‘Carrier’, kept safely by drivers and should be readily available in the driver's cab. 

An additional page may be added if necessary but it must not be inserted into the body of the 4-page document. Any further information that is needed by the driver must be provided on a separate page. 

'Instructions in Writing' details are as follows: 

  • The first page will outline the General Safety Instructions for Dangerous Goods
  • The second and third pages will define the Class-specific Hazard Characteristics and Additional Guidance illustrated by the 9 Class Danger Labels
  • The fourth page will define the Minimum Drivers Personal and Safety Equipment

Vehicle requirements are:

  • Wheel chock, suited to the size of tyre and weight of the vehicle i.e. two for articulated vehicles and draw-bar combinations on EU Journeys 
  • 2 self-standing warning signs or flashing lights in Europe, 
  • The eye-wash solution, although not required for some explosives and gases

For each of the Vehicle Crew:

  • Hi-Vis Warning Vest
  • Intrinsically safe torch (non-spark)
  • Protective gloves
  • Eye protection

Additional items required for certain Classes:

Classes 2.3 and 6.1:

  • Escape Mask

For Classes 3, 4.1, 4.3, 8, 9:

  • Plastic shovel
  • Drain seal
  • Plastic bucket

You can download a copy of the ADR 'Instructions in Writing' below.

If you employ EU Nationals whose ‘mother tongue’ isn’t English, you can download the translated version from the UNECE website at the link below 

https://www.unece.org/trans/danger/publi/adr/adr_linguistic_e.html 

Amending ADR Instructions in Writing 

Amendments cannot be made to the Instructions in Writing as the statements have been agreed upon and translated into other languages. 

Dashes may not be replaced with numbers as this could imply there is a mandatory sequence of actions. Some of these actions may not be required on every occasion. 

A company or trade association logo may be added which will be accepted in Great Britain as long as the logo does not obscure the text or make it smaller. However, other countries’ enforcement authorities may not accept such changes. If operating internationally, it is suggested that logos are not added to avoid the risk of attracting fines. 

Reproducing ADR Instructions in Writing 

The instructions may either be printed on 4 pages (as per ADR) or on both sides of 2 pages. 

EU countries reproduce theirs in exactly the same format as that in ADR, so to mitigate the risk of attracting fines when on an international journey, it is recommended that the instructions are printed on 4 pages. 

The ADR regulations state that the Instructions in Writing must be able to be read and understood by the vehicle crew but it does not prescribe the paper size to use. British enforcement authorities as a minimum will accept all four pages printed on two sides of A4 paper as long as the required text and symbols are legible. 

Displaying ADR Instructions in Writing 

If the vehicle is not carrying dangerous goods, it should not be displaying placards and so any placards should be covered up. To avoid any risk of confusion in the event of a road traffic accident, it is suggested that the Instructions in Writing are retained in the glove box or out of sight. 

If the instructions are removed from the vehicle, they must be returned to the driver the next time the vehicle is used to move dangerous goods. 

Equipment 

The list of equipment states that:

  • A drain seal is required if carrying goods with danger labels 3, 4.1, 4.3, 8 and 9. ADR does not specify what a drain seal is but could be;
    • Strong plastic sheeting, held in place by sand, sandbags or secured using a shovel to put soil or a similar product over the sheet
    • A specially made drain seal which is available commercially
    • British enforcement authorities will accept a 'sausage' of absorbent material that is sufficient in size to place around a drain opening to absorb/divert any spillage. Commercially available 'spill kits' often include such items. 
  • A collecting container is required if carrying goods with danger labels 3, 4.1, 4.3, 8 and 9.
    • The container does not need to be UN approved.
    • The container can be a bag or a bucket so long as it is capable of dealing with a spillage.
    • The container should not soften or be damaged by the substance that is to be carried in it. 
  • Under certain classes, a shovel is required for goods with danger labels 3, 4.1, 4.3, 8 and 9.
    • ADR does not specify any requirements for a shovel but it should ideally be made of plastic and have upturned sides. 

  • The additional guidance table shows that divisions 6.1 and 6.2 have the hazard characteristic 'risk to the aquatic environment and the sewerage system' 
    • There is no requirement to carry a drain seal and bucket for divisions 6.1 and 6.2 substances or to prevent leaking substances from getting into the aquatic environment or sewerage system. 

Whilst the list of equipment to be carried on page 4 of the Instructions in Writing is mandatory, pages 2 and 3 are for guidance. This guidance serves as a reminder to the driver, it is not intended to correlate with the list of equipment to be carried. 

Additional Equipment 

Additional equipment may be provided on a vehicle if required, but drivers are not expected to act as quasi-emergency responders and that if extra equipment is provided, drivers should be fully aware of what is expected of them and be provided with full training in its use. 

If the training that the driver has received means that, where safe and appropriate to do so, they can prevent leakages from getting into the aquatic environment or sewerage system and contain leaks of substances in division 6.1 and 6.2 by using a collecting container and or a drain seal, that is laudable. 

Carriers should be aware, however, of potential new hazards that may arise. For example, there might be more danger in a driver trying to deal with the leak of a toxic substance as some substances may react dangerously with the material used for the container. 

There is no rule about where on the vehicle the equipment is kept but it should be. wherever it is convenient and easy for the driver to access. Pre-journey checks should ensure that the right equipment is on the vehicle. Therefore if daily walk round defect sheets are produced internally, items of equipment can be added to the defect sheet to ensure that they are checked and not overlooked. By doing this, there is an increase in the driver/vehicle check systems which provide a more robust system of security, especially if the defect system is one which is undertaken via an ‘App’ on a mobile phone or a tablet, such as an i-pad. 

Legal Information 

This information is based upon the interpretation of the GB competent authority. This guidance note should not be taken as a complete or definitive statement of the law. It is not intended as a substitute for detailed legal or other professional advice based on specific circumstances. Transports Friend accepts no liability for any loss or damage caused by reliance on the contents of this guidance note. 

In the international carriage, competent authorities of other states may have a different interpretation of dangerous goods regulations.